LSJ - LFO MPMG MOCQA_Redacted.pdf

period with a total potential period of performance of August 15, 2026, through August 14, 2028.

The proposed LFO is to support CCIIO’s Marketplace Operations, Communications and Quality Assurance Support (MOCQA) contract GS00F221CA, task order 75FCMC21F0045 was awarded competitively using the GSA Multiple Award Schedule (MAS). The current vendor, Duty First Consulting LLC (DFC), provides continued support services for stakeholder (e.g., Health Insurance issuers and states) coordination and communication measuring stakeholder engagement; messaging and stakeholder outreach and education; support all aspects of the management of the Marketplace Plan Management Group (MPMG) operations, with a particular emphasis on Qualified Health Plan (QHP) Certification and Plan maintenance associated with DIMO/DPAR; and provides support for State Exchange Model Transitions as required under the Patient Protection and Affordable Care Act (PPACA).

To date, has been obligated to the original task order over a five-year contract; a Base Year period with four

(4) Option Year periods.

The current period of performance is:

Base Period: August 15, 2021 – August 14, 2022 Option Period 1: August 15, 2022 – August 14, 2023 Option Period 2: August 15, 2023 – August 14, 2024 Option Period 3: August 15, 2024 – August 14, 2025 Option Period 4: August 15, 2025 – August 14, 2026

The proposed LFO period of performance is:

Base Period: August 15, 2026 – August 14, 2027 Option Period 1: August 15, 2027 – August 14, 2028 Transition Out: May 15, 2028 – August 14, 2028

Program Background:

The Patient Protection and Affordable Care Act - PPACA (Pub. L. 111–148) was enacted on March 23, 2010, to assist millions of Americans in obtaining affordable health care services and to allow more employers to offer health insurance coverage in a cost-effective manner to their employees. The Health Care and Education Reconciliation Act of 2010 (Pub. L. 111–152), which amended and revised several provisions of the PPACA, was enacted on March 30, 2010. We refer to the two statutes collectively as the “PPACA.” The name “Affordable Care Act - ACA” refers to the final, amended version of the law.

The Marketplace Plan Management Group (MPMG) manages the operations and oversight of and provides technical assistance to Qualified Health Plan (QHP) issuers participating in the Federally-Facilitated Exchanges (FFE), including issuers in State Based Exchanges (SPEs) and State-based Exchanges on the Federal Platform (SBE-FPs). The meticulous management of QHP data is critical to the success of the ACA program and operations therewithin. The Annual QHP Certification cycle is executed between mid-April and October. During this time, health insurance providers create and submit detailed applications for review by CMS. Applications include data for an issuers’ entire book of QHP business, including benefit plan design, cost-sharing protocol, administrative structures, interoperability compliance, and various components required for QHP certification. The collection of issuer data submitted for QHP certification is formally referred to as the QHP Issuer Plan Inventory. In addition to Plan Inventory management, MPMG is also responsible for facilitating strategic communication across many internal and external stakeholder groups. Pertinent activities include maintaining the QHP Certification website, scheduling and moderating emergency calls with at-risk issuers, and generating final plan lists for review by state departments of insurance. To ensure the successful execution of these mission-critical tasks, MPMG has leveraged the contractual support of Duty First Consulting (DFC) for the better part of a decade to coordinate and oversee all the forementioned duties.

Overall, CMS requires the service of a qualified Vendor to best support Marketplace operations, communications and quality assurance (MOCQA) support. Communication support includes measuring QHP engagement, messaging, and stakeholder outreach and education. Operations support includes all aspects of Marketplace plan management (i.e., health insurance issuer) operations with a particular emphasis on QHP Certification and plan maintenance as well as the use of customer relationship management (CRM) tools in support of the CCIIO mission. The awarded Vendor will also support CCIIO in developing processes for and performing and documenting quantitative quality assurance (QA) reviews on data and reports to ensure that they are current, accurate, and complete. Thus, this LFO will call for the Vendor to continue to support the quality assurance and operations for selected Marketplace eligibility and enrollment functions such as those related to account transfers between Marketplace and Medicaid. And finally, the Vendor will continue to support the CCIIO Front Office mission, including but not limited to meetings and communications support for the Marketplace Operations Coordination Center as well as Marketplace data trends analyses.

3. Authority:

☒ ORDER AGAINST FSS: Authority of the Multiple Award Schedule Program, Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251, et seq.); Title 40 U.S.C. 501, Services for Executive Agencies; and Section 803 of the National Defense Authorization Act of 2002 (PL 107-107) and implemented by FAR 8.405-6. Mark the applicable exception and for each discuss how the cited authority applies in accordance with FAR 8.405-6(c)(2)(iv).

☐ An urgent and compelling need exists, and following the procedures would result in unacceptable delays (FAR 8.405-6(a)(1)(i)(A));

☐ Only one source is capable of providing the supplies or services required at the level or quality required because the supplies or services are unique or highly specialized (FAR 8.405-6(a)(i)(B)); or

☒ In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited sources procedures (FAR 8.405-6(a)(1)(i)(C)); or

MPMG launched their Plan Management Modernization Initiative (PM Mod) in 2019. PM Mod is a multi-year effort aimed at improving MPMG operations through seamless workflows, automated processing, and revamped system designs. And over the last several years, Vendor DFC has supported the Marketplace Plan Management Group (MPMG) in its multiyear modernization effort to develop the Marketplace Plan Management System (MPMS) Module, a system to manage the data for and execute the Qualified Health Plan (QHP) certification process in a more automated and efficient manner. This effort necessitates migration and transition into the MPMS Module for all data and operations that DFC currently manages in MPMG’s legacy systems (the System for Plan & Issuer Data Reporting (SPIDR) and the Plan Management (PM) Community), including plan display errors, certification issues tracking and data refresh tracking.

In the fall of 2026, MPMG plans to begin deployment of modernized functionality for its Plan Inventory and strategic communications portfolios. A successful deployment will require a full migration from the legacy Salesforce instance to the modernized Azure environment. It will also require the development of strategic communication workflows and automated data sharing prompts. MPMG is confident that it can begin to deploy these services on time and within budget with the continued support of Vendor DFC during the design, development and deployment phases.

The most critical of these data and operations is Vendor DFC’s management of all issuer and plan data, including the eligibility, certification and HealthCare.gov display status of these plans. Their team has managed SPIDR, these data, and their associated operational processes (e.g., issuer and state plan confirmation, plan withdrawals, and plan certification) since 2014 and possess a deep understanding of the details, nuances, and history around each of these components, and the criticality of these processes in ensuring the correct plans are certified by CMS and made available for sale on HealthCare.gov. As the experts in these data and operations, over the last six months, Vendor DFC has advised MPMG’s development contractor on the overarching vision, requirements, and considerations to facilitate the migration of this work from being managed and performed within SPIDR to within the MPMS Module.

MPMG’s business goals include initiating this migration by the end of 2026 and completing it by 2028. DFC’s expertise is also needed to ensure continued adherence to the migration and development timeline; to ensure a cohesive vision and plan for the entirety of this effort; and to ensure the system is designed to address existing business processes, historical context and challenges, and incorporation of pain points identified over the last 12 years. Any lag or disruption in continuity of services would risk accuracy in the plans that get certified and sent to HealthCare.gov for display, increase needed MPMG and development contractor resources—and associated costs, and delay MPMG and CCIIO’s timeline for and goals of streamlining its systems (setting up fully operational new systems and sunsetting legacy systems).

Other related risks include the rollout for the transition of data change request (DCR) operations from the PM Community to the MPMS Module, which is slated for August of 2026. The DFC team has worked alongside MPMG for over two years to advise on the necessary system requirements and conduct testing on all components of the development effort. Starting in August, MPMG will require Vendor DFC’s expertise to roll out and train external stakeholders on these new processes, provide technical assistance support, and engage with the system to perform key data change operations in advance of the 2027 and 2028 Open Enrollment Period (OEP). Any disruption of DFC services would impact the ability for MPMG to provide critical support to issuers and states in ensuring their plan data are accurate prior to being displayed on HealthCare.gov for the 2027- 2028 plan year.

And to ensure continuity of operations during this critical time of development, MPMG has now requested the current 2-year logical follow-on (LFO) in order to reduce the high risk of institutional knowledge loss and to retain services rendered by Vendor DFC beyond the current contract task order end date of August 2026. With that said, this LFO will allow Vendor DFC to continue development work with MPMG business owners and other technical developers through the deployment of Plan Inventory and strategic communication functions in the modernized environment

Other Potential Transition Risks

Beyond Vendor DFC’s support of QHP certification and related PM Modernization efforts outlined above, there are other substantial risks to CCIIO’s mission if Vendor DFC’s support were to end with the current contract period of performance end date. These risks include, but are not limited to the following:

• Continuity of support for the implementation of the Working Families Tax Cut Legislation (WFTCL) (Public Law 119-21). Vendor DFC has been supporting CCIIO since the passage of this legislation in 2025 and is the only contractor integrated in current Marketplace operations; CCIIO information technology (IT) development processes; and the process to identify, define and implement the relevant provisions by the legally mandated deadlines. Transitioning this work prior to the start of plan year (PY) 2028 risks CCIIO’s ability to meet these deadlines.

• Oklahoma (OK)’s anticipated transition to a State-based Exchange. Vendor DFC has supported the Marketplace Eligibility & Enrollment Group (MEEG) with state Exchange type transitions since 2019 and is uniquely positioned to support this transition, particularly if it needs to be executed on an accelerated timeline. Their team maintains standard documentation (e.g., the Operational Readiness and Review (ORR) Tracker as well as other documents on single, streamline application (SSApp) requirements) and has been communicating and tracking new impacts stemming from the implementation of WFTCL.

• Pre-enrollment verification. As part of the WFTCL, CCIIO must implement a pre-enrollment verification process at the Marketplace to retain its ability to find consumers eligible for premium tax credits. This requirement represents the largest shift in policy and operations in the Marketplace since the implementation of the Affordable Care Act. Vendor DFC has been integral in supporting CCIIO in interpreting the law, attending all planning sessions, and documenting decisions and action items for CCIIO. Thus, they are therefore uniquely qualified to support CCIIO in the IT development process required to implement the resulting changes.

• Marketplace Operations Coordination Center (MOCC). Vendor DFC has provided full-time support to the MOCC during the OEP since 2016. Their team has a dedicated training period to ensure staff readiness in anticipating issues and responding quickly during the OEP and to ensure an understanding of Marketplace operations, the consumer application, and familiarity with recent policy changes and system updates. Transition to a new team in August 2026 increases the risk that this support is disrupted during the critical OEP without time to adequately prepare.

• Form 1095-A Production Data Verification (PDV) Efforts. The implementation of WFTCL provisions has direct impacts on Form 1095-A generation for tax year 2026 and beyond. Vendor DFC has led Form 1095-A PDV efforts since 2015, and has been involved with discussions with CCIIO, the Internal Revenue Service (IRS), and Treasury.

Their team is integral in identifying and tracking the impacts of WFTCL and other policies on the associated data sets and processes. Transition to a new team in August of 2026 increases the cost of onboarding a new team to respond, particularly during a year with increased complexity borne of recent legislation, and in conducting meaningful analysis and supporting informed decision-making heading into the 2026 tax season.

For the reasons listed above, Vendor Duty First Consulting LLC (DFC) is considered the only source on the GSA Schedule capable of meeting this limited source action requirement and issuing this order to Vendor DFC represents the best value consistent with FAR 8.404(d) because it results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet CMS’ tasks/mission. In addition, Vendor DFC has also been identified as an above satisfactory performer on the current task order. And the hourly rates provided by Vendor DFC (GS-00F-221CA) have also been determined to be considered fair and reasonable by GSA under its Federal Supply Schedule contract. Thus, this LFO extension represents the best value to the Federal Government because: 1) it is the least costly approach from an administrative perspective and 2) provides the greatest overall benefit in response to the Marketplace Operations, Communications, and Quality Assurance Support (MOCQA) services requirement. Considering the ability of Vendor DFC to meet the needs of CMS at a fair and reasonable price – this logical follow-on extension represents an overall best value to the Federal Government

We also anticipate the Vendor’s quoted price(s) will be fair and reasonable based on historical costs, market research and published price lists which include a comparison (and potential discounts) to the Vendor’s GSA Federal Supply Schedule rates.

☐ An item peculiar to one manufacturer can be a particular brand name, product, or a feature of a product, peculiar to one manufacturer). A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. (FAR 8.405-6(b);

4. Market Research:

The original GSA task order# GS-00F-221CA / HHSM-500-2016-00052G was competed on GSA for all GSA Multiple Award Schedule (MAS) vendors in 2016 and awarded for a one-year base period followed by four (4) one-year option periods that expired on August 14, 2021. The contract requirement was then re-competed under General Services Administration (GSA) Multiple Award Schedule (MAS) and was released to seven (7) contractors; however, only one (1) quote was received. As a result, the contract was re-awarded to Duty First Consulting (GS-00F- 221CA/75FCMC21F0045) for a one-year base period followed by four (4) one-year option periods that are scheduled to expire on August 14, 2026. (75FCMC20F0011). As a result, GSA has already determined the prices of supplies and fixed price services (and rates for services offered at hourly rates) under schedule contracts to be considered fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing, except for a price evaluation as required by 8.405-2(d).

Since the original award was in accordance with the competitive procedures and based on the inability for another vendor to satisfy the technical requirements in the midst of the on-going implementation efforts while achieving a

3. CMS Competition Advocate Approval

I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

4. Head of Contracting Activity (HCA) Approval I hereby confirm the circumstances described above apply and approve the Limited Source Justification.

5. Office of Small and Disadvantaged Business Utilization

_N/A Name / Date

6. OGC Legal Review

7. HHS Competition Advocate Approval

8. Senior Procurement Executive (SPE) Approval

Based on the foregoing justification, I hereby confirm the circumstances described above apply and approve the Limited Source Justification.